Form 926-Return by a U.S. Transferor of Property to a Foreign Corporation

Form 926-Return by a U.S. Transferor of Property to a Foreign Corporation

1. 926 Form

OMB No. 1545-0026

©Attach to your income tax return for the year of the transfer or distribution.

(Rev. December 2008)

Identifying number (see instructions)

Name of transferor

Transferee Foreign Corporation Information (see instructions)
Identifying number

Name of transferee (foreign corporation)

4

3

Address (including country)

5

U.S. Transferor Information (see instructions)

Part I

Part II

Country code of country of incorporation or organization (see instructions)

6

Foreign law characterization (see instructions)

7

Is the transferee foreign corporation a controlled foreign corporation?

Yes

No

8

If the transferor was a corporation, complete questions 1a through 1d.
If the transfer was a section 361(a) or (b) transfer, was the transferor controlled (under section 368(c)) by
5 or fewer domestic corporations?

a
Yes

No
Did the transferor remain in existence after the transfer?

b
If not, list the controlling shareholder(s) and their identifying number(s):

Identifying number

Controlling shareholder

If the transferor was a member of an affiliated group filing a consolidated return, was it the parent
corporation?

c

If not, list the name and employer identification number (EIN) of the parent corporation:

EIN of parent corporation

Name of parent corporation

EIN of partnership

Name of partnership

If the transferor was a partner in a partnership that was the actual transferor (but is not treated as such under section 367),
complete questions 2a through 2d.

2

Yes

No

Yes

No

Form926(Rev. 12-2008) For Paperwork Reduction Act Notice, see separate instructions. Cat. No. 16982D

Department of the Treasury
Internal Revenue Service

1

Return by a U.S. Transferor of Property
to a Foreign Corporation

Attachment
Sequence No. 128

Have basis adjustments under section 367(a)(5) been made?

d

Yes

No

Did the partner pick up its pro rata share of gain on the transfer of partnership assets?

b

Yes

No
Is the partner disposing of its entire interest in the partnership?

c

Yes

No

List the name and EIN of the transferor's partnership:

a

Is the partner disposing of an interest in a limited partnership that is regularly traded on an established
securities market?

d
Yes

No

2. Page2 Form 926 (Rev. 12-2008)
Information Regarding Transfer of Property (see instructions)

Part III

(b)
Description of
property

Type of
property

(a)
Date of
transfer

(d)
Cost or other
basis

(c)
Fair market value on
date of transfer

Stock and
securities

Inventory

Tangible property
used in trade or
business not listed
under another
category

Intangible
property

Other property

(e)
Gain recognized on
transfer

Cash

Installment
obligations,
account
receivables or
similar property

Foreign currency
or other property
denominated in
foreign currency

Supplemental Information Required To Be Reported (see instructions):

Form 926 (Rev. 12-2008)
Assets subject to
depreciation
recapture (see
Temp. Regs. sec.
1.367(a)-4T(b))

Property to be
leased (as
described in
Temp. Regs. sec.
1.367(a)-4T(c))

Transfers of oil and
gas working interests
(as described in
Temp. Regs. sec.
1.367(a)-4T(e))

Property to be
sold (as
described in
Temp. Regs. sec.
1.367(a)-4T(d))

3. Page3 Form 926 (Rev. 12-2008)
14

16

Yes

No

Was cash the only property transferred?

Yes

No

Did the transferor transfer assets which qualify for the trade or business exception under section 367(a)(3)?

Form 926 (Rev. 12-2008)
If ªYes,º describe the nature of the rights to the intangible property that was transferred as a result of the
transaction:

b

Yes

No

17a

Was intangible property (within the meaning of section 936(h)(3)(B)) transferred as a result of the
transaction?

Type of nonrecognition transaction (see instructions)©

10

Indicate whether any transfer reported in Part III is subject to any of the following:

11

12

Yes

No

Did this transfer result from a change in the classification of the transferee to that of a foreign corporation?

Yes

No

Part IV

Additional Information Regarding Transfer of Property (see instructions)

Gain recognition under section 904(f)(3)
Gain recognition under section 904(f)(5)(F)
Recapture under section 1503(d)
Exchange gain under section 987

Indicate whether the transferor was required to recognize income under Temporary Regulations sections
1.367(a)-4T through 1.367(a)-6T for any of the following:

13

Tainted property
Depreciation recapture
Branch loss recapture
Any other income recognition provision contained in the above-referenced regulations

a
b
c
d

a
b
c
d

Yes

No
Yes

No

Yes

No

Yes

No
Yes

No
Yes

No
Yes

No

If the answer to line 15a is ªYes,º enter the amount of foreign goodwill or going concern value
transferred©

b

Yes

No

15a

Did the transferor transfer foreign goodwill or going concern value as defined in Temporary Regulations
section 1.367(a)-1T(d)(5)(iii)?

% %

(a) Before

(b) After

9

Enter the transferor's interest in the foreign transferee corporation before and after the transfer: